Document dnbBV9dOZR6rJ6z6MOn6q7Bbe

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: See Date of Section Chief Signature Below CLEAN AIR ACT INSPECTION REPORT Reserve Marine Terminals, South Shore Recycling, Napuck Salvage of Waupaca, Regency Technologies at 11600 S. Burley Avenue, Chicago, IL David Sutlin, Environmental Engineer AECAB (MN/OH) Brian Dickens, Section Chief AECAB (MN/OH) File BASIC INFORMATION Facility Name: Reserve Management Group Reserve Marine Terminals South Shore Recycling Napuck Salvage of Waupaca Regency Technologies Facility Location: 11600 South Burley Avenue, Chicago, Illinois Date of Inspection: August 9, 2021 EPA Inspector(s): 1. David Sutlin, Environmental Engineer 2. Karina Kuc, Environmental Engineer Other Attendees: 1. Hal Tolin, RMG, Principal 2. Jim Kallas, RMG, Environmental Manager 3. Dennis Stropko, RMG, Corporate Health and Safety Manager Contact Email Address: dennisstropko@reserve-group.com Purpose of Inspection: To investigate emissions from torch cutting operations and compliance with rules related to visible emissions Facility Type: Scrap Processing Regulations Central to Inspection: Illinois SIP Arrival Time: 9:30 AM Departure Time: 2:15 PM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Provided CBI warning to facility The following information was obtained verbally from RMG staff unless otherwise noted. Company Ownership: RMG is the parent company of the following subsidiaries which operate at 11600 S Burley: Reserve Marine Terminals, South Shore Recycling, Napuck Savage of Waupaca, LLC, and Regency Technologies. Process Description: Reserve Marine Terminals (RMT) The facility purchases steel and iron scrap, which is stored and dismantled outdoors using hydraulic sheers, hydraulic impact hammers, and torch cutting. In addition, large cast iron scrap is dismantled by dropping a large, forged steel ball from a crane connected to a large magnet, onto the scrap. Torch cutting is used to dismantle cast and carbon steel, that cannot be dismantled by other methods. Oxy-fuel torch cutting is performed at stations using propane as the fuel source. Before torch cutting, facility staff remove hoses, wires, fluids and other waste materials from the scrap metal. Each of the ten stations can support up to two torch cutters. A water mist cannon is used to minimize particulate emissions from torch cutting. South Shore Recycling (South Shore) The facility accepts scrap appliances from contractors, retail, and individual recyclers. Minimal dismantling of scrap is performed, and torch cutting is used only as part of equipment maintenance. Napuck Savage of Waupaca, LLC (Napuck) Page 2 of 5 Napuck recycles automotive parts to separate cast iron, aluminum and light iron. Automotive parts such as engines, rotors and drums are shipped to the facility and sorted by size. Outside, Napuck uses a cracker attachment to break the parts and separate the different metals. The facility occasionally utilizes torch cutting to separate aluminum from iron components when cracking is unsuccessful. Napuck has an uncontrolled, indoor shredder mainly for aluminum but also for some scrap they purchase from Regency. A misting cannon is utilized to control dust. A second, smaller shredder, controlled by a cyclone and baghouse, is used to further densify the aluminum scrap. An indoor propane-powered dryer is used to dry the aluminum. Regency Technologies (Regency) Regency recycles electronic scrap. They do not receive appliances from the public but rather from other businesses. When stores ship appliances without evacuating refrigerants, they notify Regency. All of Regency's operations take place indoors. They may use a torch to heat and loosen a bolt but do not perform any torch cutting. They use air tools to take apart appliances, then separate and sort the various components. Staff Interview: RMT The facility operates a single shift, Monday-Friday, and a shorter shift with a limited crew on Saturdays. The facility has a torch cutting capacity of 10 torch cutters but currently employs four torch cutters, due to a labor shortage. These operators spend the entire shift either torch cutting or preparing the scrap for cutting by removing waste material. The facility does not torch-cut stainless steel or cast iron. In addition to the water cannon, other steps that RMT has taken to mitigate emissions from torch cutting include the construction of an 8-foot-tall wall east of the torch-cutting stations, performing torch cutting below adjacent scrap piles, and intentionally locating the cutting stations near the center of the facility. South Shore As of 2019, South Shore is exclusively using contracts in order to verify proper recovery of refrigerants from appliances. Its current policy is to reject appliances that arrive with cut refrigerant lines. Regency Scrap may be sold from Regency to Napuck for further processing. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: At RMT, EPA observed and took a series of digital photos of two operators torch-cutting a steel pipe. The observation lasted approximately 15 minutes. Minor, intermittent visible emissions were observed. Page 3 of 5 At South Shore's indoor operations, EPA inspected the queue for appliances requiring refrigerant recovery and observed multiple appliances with cut refrigerant lines. Staff explained that the refrigerant recovery for these appliances was performed outside the building to allow peddlers to then dismantle the appliances and sell the component metals to South Shore separately. Photos and/or Videos: were taken during the inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility With regard to proper recovery of refrigerants, EPA emphasized the importance of the rules in preventing the improper cutting of refrigerant lines. Requested documents: South Shore refrigerant recycling contracts RMT's torch make and model RMT's fugitive dust plan RMT's daily visible emission observation logs Torch cutting production records DIGITAL SIGNATURES DAVID Digitally signed by DAVID SUTLIN Report Author: _S_U__T_L_I_N_______D07a_:t1e_5::25_032_-10_.51'0_0.00_'6____________ Brian Digitally signed by Brian Dickens Section Chief: _D__ic_k_e_n_s_______D07a_:t4e_6::2_208_2-10_.51'_00.00_'6_____________ Page 4 of 5 Facility Name: RMG Facility Location: 11600 S Burley Ave, Chicago, IL 60617 Date of Inspection: August 9, 2021 APPENDICES AND ATTACHMENTS 1. Digital Image Log Page 5 of 5 Facility Name: RMT Facility Location: 11600 S Burley Ave, Chicago, IL 60617 Date of Inspection: August 9, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Karina Kuc 2. Archival Record Location: C:\Users\Dsutlin\OneDrive Environmental Protection Agency (EPA)\Inspections\2021\RMG\Inspection\Inspection Photos\ Date and Time Image Number File Name (incl. time zone and DST) Description of Image South Shore: appliance in refrigerant 1 IMG_0461.JPG 8/9/2021 12:23 recovery area South Shore: appliance in refrigerant 2 IMG_0462.JPG 8/9/2021 12:24 recovery area South Shore: refrigerant recovery 3 IMG_0463.JPG 8/9/2021 12:29 equipment RMT: hydraulic impact hammer used 4 IMG_0469.JPG 8/9/2021 13:46 to dismantle scrap South Shore: sign with notification of 5 IMG_0470.JPG 8/9/2021 14:20 refrigerant policy South Shore: sign with notification of 6 IMG_0471.JPG 8/9/2021 14:20 refrigerant policy South Shore: close-up of sign with 7 IMG_0472.JPG 8/9/2021 15:45 notification of refrigerant policy Water cannon operating during torch 8 MVI_0465.MOV 8/9/2021 8:00* cutting 9 MVI_0466.MOV 8/9/2021 8:08* Torch cutting operations 10 MVI_0467.MOV 8/9/2021 8:26* Torch cutting operations Operation of forged steel ball drop 11 MVI_0468.MOV 8/9/2021 8:43* used to dismantle large cast iron scrap IMG_0352.JPG - 12 IMG_0406.JPG 8/9/2021 13:18 - 13:31 Photos of torch cutting operations Note: *the timestamps displayed on the movies are incorrect and should be five hours later. 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